June 14, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (209) 870-3255

Steven A. Rosso
President and Chief Executive Officer
Pacific State Bancorp
1899 W. March Lane
Stockton, CA 95207

	Re:	Pacific State Bancorp
		Form 10-K for the year ended December 31, 2004
		File No. 0-49892

Dear Mr. Rosso:

      We have reviewed your filing and have the following comment.
We have limited our review to matters related to the issues raised
in
our comment.  Where indicated, we think you should amend your
filing
in response to this comment.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Annual Report to Shareholders - Exhibit 13

Financial Statements

Report of Independent Registered Public Accounting Firm, page 20

1. Please revise to include an audit report from your independent
accountants that properly evidences the signature of the firm that
issued it.  Refer to Item 302 of Regulation S-T.

*    *    *    *


      As appropriate, please amend your filing and respond to this
comment within 10 business days or tell us when you will provide
us
with a response.  Please furnish a cover letter with your
amendment
that keys your response to our comment.  Please file your cover
letter on EDGAR.  Please understand that we may have additional
comments after reviewing your amendment and responses to our
comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Isa Farhat at (202) 551-3485 or me at (202)
551-3851 if you have questions regarding comments on the financial
statements and related matters.



      Sincerely,


						Paul Cline
						Senior Accountant


Steven A. Rosso
Pacific State Bancorp
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